News and topics of interest to financial institutions regulated by the Department of Banking and Finance Inside this issue: Community 2 Development Financial Institutions Fund Low Income 2 Designation for Credit Unions Upcoming FASB 2 Lease Accounting Changes Reminder Action on Applications 3 for the Month Internet Deposits and Liquidity March 2017 Effective liquidity risk management is essential for the safety and soundness of financial institutions. In fact, the inability of an institution to meet its cash letter can result in the loss of its charter. The increased use of non-core funding sources and strategies can result in increased complexity and the need for increased liquidity oversight. Generally, non-core funding resources include deposits originating outside of the local trade area; however, these deposits may be restricted under certain conditions. Additionally, if the overall financial condition of the institution is deteriorating or if the risk profile of the institution is increasing, carefully consideration should be given to the impact that changes in the permissibility of retaining or obtaining non-core deposits could have on liquidity levels, projections and planning. Management should have access to information systems that separate and measure the level of funding from deposits in its local trade area from deposits obtained outside the local trade area such as deposits obtained through listing services or brokers. This information may become critical to planning in the event an institution is restricted from certain deposit products and services. Institutions are encouraged to confer with Federal regulators to confirm assumptions about deposit categorization to build appropriate management reports. Deposits generated through listing services meet the Federal Deposit Insurance Corporation (FDIC) definition of brokered deposits if rates exceed the prevailing national market rate as determined by the FDIC, by 75 basis points. The national rate is based on historical data that lags market movements, which can have a limiting, material impact on rates available to your market, particularly in a rising rate environment. While banks operating in a high market rate environment may qualify for a different calculation, each branch of an institution in the market area is accounted for in the national market rate calculation, which can have a material impact on the result. Management should understand the calculations behind rate limitations to build appropriate management reports. Deposits that meet the Federal definition of a brokered deposit may not be available to be accepted, renewed, or rolled over when an institution is no longer considered to be "well capitalized," which can result from capital ratios dropping below established benchmarks, regulatory determinations resulting from administrative actions, or other notification from the Federal regulator. Institutions that fall below "adequately capitalized" are prohibited by FDIC regulation from accepting, renewing, or rolling over any brokered deposits. New Method for Department's Electronic Press Releases Goes LIVE! Effective April 3, 2017, all Department of Banking and Finance (Department) press releases delivered through electronic means, including emails regarding the Monthly Bulletin Financial Institutions Today and proposed/final rules and regulations, will be delivered via the govdelivery.com domain. Please visit our website to manage your subscription. Page 2 March 2017 Community Development Financial Institutions Fund The Community Development Financial Institutions (CDFI) Fund offers resources and programs that invest federal dollars alongside private sector capital by serving mission-driven financial institutions that take a market-based approach to supporting economically disadvantaged communities. These mission-driven banks, credit unions, and other qualified financing entities are encouraged to apply for CDFI certification. To date, federally-chartered institutions have expressed the most interest in the CDFI Fund. Certified CDFIs are eligible to apply for awards through a variety of programs offered by the CDFI Fund. These awards allow CDFIs to finance an array of activities, including mortgage lending for first-time homebuyers, flexible underwriting for community facilities, and commercial loans for businesses in low-income areas. Financial assistance from the CDFI Fund may be in the form of a grant, secondary capital, nonmember deposit, or loan. To apply for CDFI certification, your organization must submit an application to the CDFI Fund for review. The CDFI Certification Application must demonstrate that the applicant meets each of the following requirements: Is a legal entity at the time of certification application; Has a primary mission of promoting community development; Is a financing entity; Primarily serves one or more target markets; Provides development services in conjunction with its financing activities; Maintains accountability to its defined target market; and Is a non-government entity and not under the control of any government entity (Tribal governments excluded). The CDFI Fund hosts monthly CDFI certification conference calls to serve as a forum for potential CDFI certification applicants, certified CDFIs, and other CDFI certification stakeholders to ask questions and learn more. Information about the dates for these calls is available on their website, https://www.cdfifund.gov/. Information about this program is also available on the National Credit Union Administration (NCUA) website provided by the Office of Small Credit Union Initiatives on their website, https://www.ncua.gov/About/leadership/Pages/small-credit-union-initiatives.aspx. Low Income Designation for Credit Unions Low Income Credit Union (LICU) is a designation defined in Section 701.34 of the NCUA Rules and Regulations. Statechartered credit unions that meet the eligibility requirement may obtain LICU designation from the NCUA, subject to the approval of the Department. LICU designation confers access to specified benefits and expanded authority as long as the credit union continues to meet the eligibility requirements. The Department supports LICU designation for state-chartered credit unions that are well managed and in a satisfactory financial condition. Applicants should provide a strategic plan that is consistent with standards of safety and soundness that includes a clearly defined business plan outlining the use of the additional powers granted and exit strategies should the institution no longer qualify as a LICU. In order to maintain LICU designation, the credit union must continue to meet the eligibility requirements. Changes in the credit union's membership demographics, field of membership, or completion of a merger are among the circumstances which may result in the credit union no longer meeting the eligibility requirement. Accordingly, the credit union should have contingency plans to achieve strategic initiatives for the possibility of losing LICU designation. If a LICU is found to no longer meet the eligibility requirement, the credit union may be granted up to five (5) years to either meet eligibility requirements or lose the LICU designation and related benefits. For more information, please review the NCUA's Low Income Designation Fact Sheet at https://www.ncua.gov/Legal/ Documents/LowIncomeDesignationFactSheet.pdf. Upcoming FASB Lease Accounting Changes Reminder Lessees will be required to recognize assets and liabilities on the balance sheet for the rights and obligations created by all lease terms of more than 12 months under an accounting standard update announced in February 2016, which becomes effective for public companies with fiscal years (and interim periods within those years) beginning after December 15, 2018, and all other organizations with fiscal years beginning after December 15, 2019, and interim periods beginning after December 15, 2020. Early application is permitted. Prior to this change, only capital leases were required to be recognized on lessee balance sheets. This change is designed to improve transparency and comparability. Refer to Accounting Standards Update No. 2016-02 for more information. Page 3 March 2017 Action on Applications for the Month The following is a summary of official action taken on applications by state financial institutions under Title 7, Chapter 1 of the O.C.G.A. and petitions for certificate of incorporation of financial institutions and other matters of interest during the month of March 2017: APPLICATIONS FOR NEW FINANCIAL INSTITUTION FINANCIAL INSTITUTION Pacific Metro Bank 11625 Medlock Bridge Road Johns Creek, GA 30097 Fulton County CAPITALIZATION $ 12,000,000 APPROVAL DATE Pending BEGIN BUSINESS DATE APPLICATIONS TO ESTABLISH A BRANCH OFFICE FINANCIAL INSTITUTION BRANCH OFFICE APPROVAL DATE SunTrust Bank Atlanta Hill Center 201 Franklin Road, Suite 100 Brentwood, TN 37027 Williamson County 06-20-2016 BEGIN BUSINESS DATE 03-20-2017 SunTrust Bank Atlanta Synovus Bank Columbus Synovus Bank Columbus Pinnacle Bank Elberton LGE Community Credit Union Marietta Exchange Bank Milledgeville Associated Credit Union Norcross Fox Mill Centre 6723 Fox Centre Parkway Gloucester, VA 23061 Gloucester County Overton 3400 Overton Park Drive Atlanta, GA 30339 Fulton County Reynoldstown 144 Moreland Avenue Atlanta, GA 30307 Fulton County Parkway Place 1081 Parkway Place Athens, GA 30606 Oconee County Jonquil Shopping Center Atlanta Road & Spring Road Smyrna, GA 30080 Cobb County Lake Sinclair 2801 North Columbia Street Milledgeville, GA 31061-3326 Baldwin County Dawsonville 4200 Dawson Forrest Road Dawsonville, GA 33989 Dawson County Pending 03-13-2017 03-13-2017 03-06-2017 03-13-2017 08-22-2014 03-08-2017 03-13-2017 Page 4 Coosa Valley Credit Union Rome The Bank of Soperton Soperton First State Bank Wrens Cartersville Walnut Grove Road Cartersville, GA 30165 Bartow County Vidalia 121 Church Street Vidalia, GA 30474 Toombs County Warrenton 189 Legion Drive Warrenton, GA 30828 Warren County 03-28-2017 March 2017 01-11-2017 03-16-2017 01-25-2017 03-15-2017 FINANCIAL INSTITUTION SunTrust Bank Atlanta SunTrust Bank Atlanta SunTrust Bank Atlanta APPLICATIONS TO CHANGE LOCATION CHANGE LOCATION OF APPROVAL DATE West End From: 1715 West End Avenue Nashville, TN 37203 Davidson County Pending To: 210 21st Avenue South Nashville, TN 37203 Davidson County Rhode Island Row From: 410 Rhode Island Avenue NE Washington, DC 20002 To: 2350 Washington Place NE Washington, DC 20018 09-16-2016 Kennesaw Marketplace From: 1184 Barrett Parkway Kennesaw, GA 30144 Cobb County To: 1340 Ernest W. Barrett Parkway NW Kennesaw, GA 30152 Cobb County 12-23-2016 EFFECTIVE DATE 03-24-2017 03-31-2017 PREVIOUS NAME Mead Employees Credit Union Atlanta NOTICE OF CHANGE IN NAME NEW NAME MECU APPROVAL EFFECTIVE DATE DATE 03-03-2017 FINANCIAL INSTITUTION (SURVIVOR) SRP Federal Credit Union North Augusta, SC FINANCIAL INSTITUTION MERGERS MERGED INSTITUTION APPROVAL EFFECTIVE DATE DATE Richmond County Health Department Employees Credit Union Augusta, GA Pending Page 5 March 2017 Holiday Observance Office Closing The Department will be closed on Monday, April 24th for a State Holiday. DFB OUTREACH AND UPCOMING SPEAKING ENGAGEMENTS: Georgia Credit Union Affiliates 2017 Annual Convention Commissioner Kevin Hagler will be speaking at the GCUA 2016 Annual Convention in Savannah on Friday, May 19. For more information about this event visit https://gcua.org/index.php. Community Bankers Association of Georgia Banker Regulator Forum Deputy Commissioner for Supervision Melissa Sneed will be participating on a regulatory panel for the "Banker Regulator Forum-2nd Quarter" of the Community Bankers Association of Georgia (CBA) in Atlanta on Thursday, May 4. The CBA invites questions and suggested hot topics at http://web.cbaofga.com/events/Banker-Regulatory-Forum-2nd-Quarter-54174419/details. Georgia Bankers Association Georgia Banking School Supervisory Manager Justin McElheney will participate in the Georgia Banking School of the Georgia Bankers Association (GBA) in Athens on Tuesday, May 2nd through Thursday, May 5th. He will be assuming the role of "bank examiner" for third year students as they compete in teams for the best performance managing assets and liabilities in a changing rate environment. For more information about GBA visit http://www.gabankers.com. The Department is the state agency that regulates and examines Georgia state-chartered banks, state-chartered credit unions, state-chartered trust companies, and bank holding companies that own Georgia state-chartered financial institutions. The Department also has responsibility for the supervision, regulation, and examination of Merchant Acquirer Limited Purpose Banks chartered in Georgia. In addition, the Department has regulatory and/or licensing authority over mortgage brokers, lenders and processors, mortgage loan originators, check cashers, sellers-issuers of payment instruments, money transmitters, and international banking organizations. Our Mission is to promote safe, sound, competitive financial services in Georgia through innovative, responsive regulation and supervision. Our Vision is to be a willing and able partner with our regulated entities in order to support vibrant economic growth and prosperity in Georgia. Subscribe to Receive this Publication: This publication is delivered to interested parties via e-mail and is also available from the Department's website at: http://dbf.georgia.gov/ under Publications, Financial Institutions Bulletin. To subscribe to this publication, please visit https://bkgfin.dbf.state.ga.us/GovDelivery.html. NEW Department of Banking and Finance 2990 Brandywine Road, Suite 200 Atlanta, Georgia 30341-5565 Phone: (770) 986-1633 Fax: (770) 986-1654 or 1655 http://dbf.georgia.gov/